By now you may have heard about the new FDA law that regulates cosmetics. The Modernization of Cosmetic Regulation Act of 2022, or MoCRA, is the most significant expansion of regulations into the cosmetic industry since the expansion of the FDA to include cosmetics in 1938. The benefit to emu farmers who also sell emu oil and emu oil products is that it will require a few extra steps to ensure the safety of the consumer. In most cases that includes registration of their products and in some cases a registration of your facility with the FDA for Cosmetics. It all depends on your level of involvement in the supply chain. If you are a farmer, who sells emu fat, but you don’t produce or sell any products, you do not have to do anything. If you are a consumer of emu oil products, rest assured that you are now consuming safer products. If you simply sell emu oil products under someone else’s label, and your company name is not on it, you don’t need to do anything. If you sell products under your name or company name you are a distributor and you must register your product with the FDA, but you are not required to register your facility. If you make, repackage, or change the product in any way, you are a manufacturer and you must register your facility and your product with the FDA. That last category is a little more involved and I suggest reading up on the FDA regulations for cosmetic manufacturers.
